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  • C. Seidler Table of Contents

    DRAFT Concept Paper of Proposed Early Action for Residential

    Refrigeration Measure

    I. Overview........................................................................................................1 II. Background....................................................................................................1

    Need for Regulations: ................................................................................1 Overview of Sector (Current Control Practices): ........................................2 Current Regulatory Requirements:.............................................................4

    III. Emissions Inventory......................................................................................5 IV. Availability and Technological Feasibility:......................................................6 V. Possible ideas for Reducing GHG Emissions:...............................................6 VI. Emission Reduction Potential ........................................................................7 VII. Cost Information: ...........................................................................................8

    Consumer Cost and Cost Savings: ............................................................8 Utility Industry Cost and Cost Savings: ......................................................9 Appliance Recycling Cost:........................................................................10

    VIII. Outstanding Questions/Barriers/Issues ......................................................11 IX. Other Environmental Benefits of Potential Strategies.................................11 X. Key Stakeholders .......................................................................................11 XI. Related Studies Underway .........................................................................12 XII. Citations .....................................................................................................13

  • C. Seidler March 3, 2008 Page 1

    I. Overview This measure involves establishing a voluntary program to upgrade pre-2002, less energy efficient residential refrigerators and freezers as the older units reach their end-of-life (EOL) and to ensure proper recovery of refrigerants and foam blowing agents that have high global warming potential (high-GWP). At the program start the vast majority of appliances recycled will be inefficient, pre-1996 refrigerators using greenhouse gas (GHG) refrigerants and foam blowing agents totaling about 9,900 metric tons carbon dioxide equivalent (MTCO2E) per appliance followed by a transition to pre-2002 refrigerators using refrigerants and foam blowing agents that translate into about 1,350 MTCO2E per appliance. The measure is expected to include developing strategies to support appliance take-back/upgrade and early retirement programs (generally referred to as early retirement programs throughout document) such as the U.S. Environmental Protection Agency (US EPA) Responsible Appliance Disposal (RAD) program1 and EnergyStar program, in addition to programs administered by local utilities to address domestic appliances energy efficiency, which also result in direct and indirect GHG emission reductions. This measure will be coordinated with the Foam Recovery/Destruction measure, another early action measure that is expected to require EOL recovery of high-GWP refrigerants and foam blowing agents from appliances. The Residential Refrigeration program will focus on operating refrigerators, while the Foam Recovery/Destruction measure will focus on non-operating refrigerators. This measure will focus on increasing the number of refrigerators entering the waste stream that will be properly recycled to reduce GHG emissions. If all waste refrigerant, foam, and other materials are properly recycled,2 direct GHG emissions avoidance benefits may be significant, which will also lead to reductions in indirect GHG emissions due to the use of more efficient units. Based on California law all appliances are required to be recycled and the refrigerant recovered, but there is no requirement to recover foam blowing agents. A primary benefit of this measure would be to ensure recycling of appliances including the recovery and destruction of foam blowing agents.

    II. Background

    Need for Regulations: Specific to residential refrigeration there is not an anticipated need for regulations. The California Global Warming Solutions Act of 2006 (AB 32) requires the Air Resources Board (ARB) to adopt a statewide GHG limit equivalent to the statewide GHG levels in 1990 to be achieved by 2020. ARB staff identified residential 1 A foam recovery program for appliances is currently operating as an incentive program between US EPA and utility companies, some of which are located in California (Responsible Appliance Disposal program, or RAD, http://www.epa.gov/ozone/snap/emissions/radp.html). The program was started in 2006 and the success of the program has not been gauged yet, although it is anticipated that a mandatory program would be more effective. 2 Proper recycling of an appliance for the purpose of this measure means all materials are recycled and all high-GWP GHGs from refrigerants and foams are destroyed.

  • C. Seidler March 3, 2008 Page 2

    refrigeration as a source of emissions of high-GWP GHGs that include chlorofluorocarbons (CFC), hydrochlorofluorocarbons (HCFC), and hydrofluorocarbons (HFC). In AB 32 the definition of GHGs includes carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. As these same gases are listed in the Kyoto Protocol they are commonly referred to as Kyoto gases. Although CFC and HCFC are ozone depleting substances (ODS) that are not listed as GHGs under the Kyoto Protocol (referred to as non-Kyoto gases) nor explicitly listed in AB 32, they represent a significant volume of banked high-GWP GHGs that are a potential source of continued emissions for several more decades, due to the long lifespan of appliances. The US EPA estimates that nearly 10 million refrigerators and freezers are disposed of in the U.S. each year.3 By multiplying the 10 million refrigerators and freezers by the percentage of the U.S. population residing in California (12.13%) the total annual disposal in California is estimated at 1.2 million refrigerators and freezers. Pre-1996 appliances contain CFC refrigerants and foam blowing agents, pre-2002 appliances contain HFC refrigerants and HCFC foam blowing agents, and post-2002 appliances contain HFC refrigerants and foam blowing agents. CFC and HCFC are ODS; CFC, HCFC, and HFC are all high-GWP GHGs. Federal and State laws and regulations require the recovery of all refrigerants for destruction or reclamation, but there are no laws or regulations governing the management of foam blowing agents at an appliance EOL. If high-GWP GHGs are not recovered from foams at EOL, they will be released in large part to the atmosphere during shredding and landfilling. Recovery of insulating foams from appliances has been demonstrated to be technologically and economically feasible in California through current appliance early retirement programs managed by utility companies, with collected appliances processed by Appliance Recycling Centers of America, Inc. (ARCA) and JACO Environmental, Inc.4

    Overview of Sector (Current Control Practices): The Montreal Protocol focused on the decision to phase out the production and consumption of ODS in products worldwide. In the United States this was accomplished with the passage of the Clean Air Act (CAA). The US EPA issued a rule in July, 1992 requiring the gradual reduction in the production of CFC and for producers to phase them out completely by January 1, 2000.5 In order to meet the HCFC production and consumption limits set under the Montreal Protocol, the US EPA issued 3 US EPA, Appliance Disposal Practices in the United States, http://www.epa.gov/Ozone/partnerships/rad/raddisposal_factsheet.html, retrieved February 27, 2008. 4 Southern California Edison Safeguarding the Environment One Appliance at a Time, http://www.epa.gov/ozone/partnerships/rad/downloads/RAD_SCE_Case_Study.pdf, retrieved February 28, 2008. 5 The Accelerated Phaseout of Class I Ozone-Depleting Substances, http://www.epa.gov/ozone/title6/phaseout/accfact.html, retrieved April 18, 2008.

  • C. Seidler March 3, 2008 Page 3

    an accelerated phase out of the production and importation of HCFC-141b, HCFC-142b, and HCFC-22.6 In all developed countries, household refrigerators were redesigned to perform with CFC substitutes by the end of 1996. In the U.S., as in many other countries in the developed world, this redesign was undertaken by assessing the replacements for CFC in terms of product performance, ozone depletion, global warming, toxicity, flammability, economics, and energy efficiency. These undertakings resulted in several different solutions globally.7

    Fluorocarbons play two roles in home refrigerators - refrigerant and foam insulation blowing agent. The use of refrigerants and blowing agents vary from year to year with the use of CFC, HCFC, HFC, and other CFC substitutes. Table I summarizes the progression that has occurred in the use of the most common, but not only, refrigerants and foam blowing agents for developing countries over three timeframes as the phase out of ODS continues.

    Table I Refrigerant and Foam Blowing Agent Use Pr ogression 8 Function

    (Timeframe) Pre-Montreal Protocol

    (before 1996) Transitional (1996-2005)

    Non-Ozone Depleting (2003 and beyond)

    Refrigerant CFC-12 HFC-134a Isobutane HFC-134a Isobutane